Japanese Bankers Association (JBA)

InfluenceMap Score
for Sustainable Finance Policy Engagement
Performance Band
Organization Score

Tokyo, Japan

The Japanese Bankers Association (JBA) appears to have had some engagement with sustainable finance policy and is a member of the Expert Study Group hosted by Japan’s Financial Service Agency. It has supported the role of finance in meeting the goals of the Paris Agreement. However, Makoto Takashima, JBA’s chairman, stated in a Bloomberg interview in 2021 that continued financing of fossil fuel industries in order to transition is necessary to achieve carbon neutrality. JBA has advocated for policymakers in Japan to support sustainable finance regulation.

In response to the EU Commission's Consultation on the Renewed Sustainable Finance Strategy in 2020, JBA offered broad support for TCFD disclosures, but it is unclear whether it supports regulatory implementation for corporate ESG disclosures. In two different TCFD consultations during 2021, JBA did push back against the disclosure of Scope 3 emissions for the financial sector, also arguing that certain metrics have not been standardized so might not be comparable. However, JBA did appear to support the establishment of internationally recognized sustainability reporting standards by the IFRS.

JBA has been particularly engaged on the EU Taxonomy process, mostly with negative positions. During 2019, JBA argued that the taxonomy should not be too prescriptive on the basis that it may be used as a reference in regions outside the EU and suggested that non-EU taxonomies should take into account economic factors. In response to the EU Commission's Consultation on the Renewed Sustainable Finance Strategy in July 2020, JBA stated that the scope of the EU Taxonomy was extremely narrow and recommended a less stringent system for classifying sustainable investments. It again restated its support for a gradual approach of classifying sustainable investments in response to the EU Commission in December 2020, June 2021 and September 2021. Also in 2021, JBA did not appear to support certain characteristics of the expansion of the taxonomy to cover harmful activities, such as the “No Significant Impact” criteria at this stage.

In response to the EU Commission's Consultation on the Renewed Sustainable Finance Strategy in July 2020, JBA argued for a less stringent approach to the EU Green Bond Standard. In comments to UK’s Prudential Regulation Authority (PRA) in 2019, JBA suggested that PRA's proposals on enhancing banks' and insurers' approaches to managing financial risk from climate change should not become mandatory requirements.

In 2020, in comments to the European Central Bank climate-related risks, JBA stated that the scope of regulatory requirements should be limited to entities established in the EU and requested the coordination with regulators from other jurisdictions. Similarly, in comments to the European Banking Authority on prudential ESG disclosures standards in 2021, JBA has highlighted the need to consider third country regulatory requirements and has argued against detailed disclosures. During the 7th Sustainable Finance expert group meeting, JBA showed some broad support for the integration of ESG factors into risk management.

JBA has disclosed policy positions for all relevant sustainable finance policies, with some detail of activities on the ‘News’ section of its website. JBA has full disclosure of its members, including companies and individuals holding key positions in the executive and key committees.

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